ContractColumbia Funds Series Trust • March 3rd, 2022
Company FiledMarch 3rd, 2022January 21, 2022 Columbia Funds Series Trust Columbia Funds Series Trust II 290 Congress street 290 Congress Street Boston, Massachusetts 0221 0 Boston, Massachusetts 02210 BMO Funds, Inc. 790 North Water Street, Suite 1100 Milwaukee, Wisconsin 53202 Ladies and Gentlemen: Columbia Fund Series Trust, a Delaware statutory trust, and Columbia Funds Series Trust II, a Massachusetts business trust (each an “Acquiring Company” and collectively, the “Acquiring Companies”), on behalf of each of its series listed on Schedule A attached hereto and incorporated herein by reference,1 and BMO Funds, Inc., a Wisconsin corporation (the “Target Company” and together with the Acquiring Companies, each a “Company” and collectively, the “Companies”), on behalf of each of its series listed on Schedule A, have requested our opinion regarding certain federal income tax consequences of the reorganization (each a “Reorganization” and collectively, the ‘‘Reorganizations”) of each Target Fund listed